Document: MOTION
Link: [Open PDF](https://42o.org/l3g4l/589.0 MOTION 2024-03-26 .pdf)
Filing Date: 2024-03-26
Summary (Justice Demanded)
Title: MOTION
Aaron Surina, the respondent of a court case involving the relocation of his minor children, challenges a court ruling and seeks its reconsideration. He asserts that the ruling was significantly influenced by the unethical conduct of Counsel Stanley Kempner Jr., who he alleges misrepresented facts and previous court orders. Consequently, this resulted in the unjust re-litigation of previously resolved matters and a significant misinterpretation of prior hearings and orders.
Surina contends that these actions led to an unfavorable outcome that did not prioritize the best interests of his children, a crucial requirement as per RCW 26.09.260 and related statutes. He also alleges that his rights under RCW 26.09.260, 26.09.500, 26.09.450, 26.09.460, and 26.09.510 were disregarded, asserting that the court failed to recognize his legal right to propose modifications in light of significant changes in circumstances.
The motion further indicates a gross lack of fairness in the proceedings, predominantly due to Counsel Kempner’s actions. Kempner, despite his extensive legal experience, seemingly disregarded statutory guidelines for custody modification following relocation and failed to prioritize the children’s best interests. Such oversight reflects an unprofessional and unjust approach to the case.
Surina argues that judicial bias is evident as the court allowed factual misrepresentations and misunderstandings of previous court decisions to influence the proceedings. This bias led to rulings that deviated from Washington State law and failed to prioritize the children’s best interests. Consequently, Surina calls for the reconsideration of these rulings, including the relocation and custody modification orders he believes were unjustly made.
Surina also alleges local collusion, suggesting that the legal process has been manipulated to circumvent statutory mandates. This perceived unethical conduct has led to a sense of systemic bias, resulting in frustration and a sense of injustice. Nevertheless, Surina remains steadfast in his pursuit of justice for his children, seeking a fair resolution that prioritizes their welfare and stability.
In his motion, Surina seeks to expunge any proceedings or orders based on factual misrepresentations, secure primary custody of his children, endorse a revised parenting plan, uphold the children’s placement in the Spokane School District 81, and impose any further relief deemed just and appropriate. His requests underscore his pursuit for justice, fairness, and ethical conduct in these legal proceedings.
In conclusion, Surina’s motion for reconsideration of the court’s ruling emphasizes claims of bias, misinterpretation of law, and unethical conduct, all of which he argues have wrongfully influenced the initial decision.
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